This Privacy Statement applies to Vertus Group (“Vertus”) and to businesses in the Vertus portfolio of companies (collectively, the “Company Group,” “we,” “us,” “our”) and covers our processing activities as a data controller. This Privacy Statement applies to personal information collected through our websites any of our mobile sites (collectively, the “Sites”) our mobile applications (“Apps”), or anywhere else that we link to this Privacy Statement, and to information collected by phone, email, or offline methods (collectively, the “Services”).  The Services are owned and operated by Vertus Group as a data controller, with its principal place of business at 8133 Warden Avenue, Suite 400, Markham, ON L6G 183, Canada. This Privacy Statement does not apply to personal information we process as a service provider or data processor on behalf of our business customers, which is governed by contracts with our customers and the privacy notices of our customers.

This Privacy Statement explains:

• What personal information we collect, and why we collect it;
• How we use that information;
• How we protect that information;
• How you can control your information, including accessing, updating and deleting what we store; and
• How we share information collected.

Please review this Privacy Statement carefully and be sure you understand it prior to using the Services. Your use of the Services is deemed to be acceptance of this Privacy Statement. If you do not agree to this Privacy Statement, you should not use, and should immediately terminate your use of, the Services.  

INFORMATION WE COLLECT AND HOW WE COLLECT IT

For purposes of this Privacy Statement, personal information is information that directly or indirectly identifies you or can be used to identify you as an individual. Personal information does not include: aggregated, de-identified or anonymized information that cannot be associated with or linked to you or a particular household; or publicly available information from government records that we reasonably believe is lawfully available to the general public.
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Information You Provide
We may collect or process personal information which you provide to us or our service providers through use of the Services, such as completing forms on the Sites, through questions you send to us or through other means of communication between you and us.

The categories of personal information you provide may include:

• first and last name;
• job title and company name;
• company email address;
• company phone number;
• company mailing address;
• username and password to register with us;
• your professional interests;
• any other identifier that permits us to contact you or information you choose to provide to us.

Information Collected Automatically

We or our service providers may also collect, store, use and otherwise process information about your visits to the Sites and Apps about your computer, tablet, mobile or other device through which you access the Sites or Apps.

This includes the use of cookies, pixels, or other online tracking technologies to personalize your experience, customize advertisements to you, and to improve the Services. We may use these technologies to collect the following information:

• technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and general geographical location; and
• information about your visits and use of the Sites or Apps, including the full Uniform Resource Locators  (URL), clickstream to, through and from the Sites, pages you viewed and searched for on the Sites, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and navigations and search terms used on the Sites.

You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of the Sites. For more information on our use of cookies and other online tracking technology, please visit our Cookie Policy.
 

The Sites also use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the Sites analyze how users use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can learn more about Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout.
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Regional Defaults: How these technologies run depends on where you are located. For visitors in the United States, both analytics and advertising technologies run by default and you may opt out at any time (an opt-out model). For visitors in Canada outside of Quebec, analytics runs by default and you may opt out, while advertising technologies remain off unless you turn them on (an opt-in model). For visitors in Quebec, the European Economic Area, the United Kingdom, and Switzerland, and where we cannot determine your location, non-essential analytics and advertising technologies remain off until you affirmatively consent (an opt-in model).

Job Applicant Information

We also collect personal information from job applicants in connection with administration of our human resources programs and functions, including, with respect to: job applications and hiring and recruiting programs, and other employment related purposes.

The categories of personal information we may collect from potential job applicants include:

• first and last name;
• date of birth;
• gender;
• bank account information;
• Social security, driver’s license, state identification card, or passport number;
• racial or ethnic origin or citizenship or immigration status;
• health conditions or restrictions;
• employment history;
• background record check information;
• education background and information; and
• any other information you may provide in connection with your employment application.

DO-NOT-TRACK SIGNALS

Some browsers have a Do-Not-Track ("DNT") feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity online tracking technologies. Those features are not all uniform. Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control (“GPC”). You may need to use a specific browser or an extension that supports these tools and universal signals. When detected, we will process such a signal as a request to opt out of tracking and as a request to opt out of “sale” or “sharing” of your data as explained in the “Your Privacy Rights” section below. If you have questions, please contact us via one of the methods listed in the “Contacting Us” section at the end of this Privacy Statement.

COMPANY GROUP AS DATA CONTROLLER

This Section of our Privacy Statement applies to persons located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland. This Section describes how we collect, use, disclose or otherwise process personal data of persons within the scope of the EU General Data Protection Regulation (“EU GDPR”), the UK Data Protection Act, and the Swiss Federal Act on Data Protection. For purposes of this Section, the term “personal data” means any information relating to an identified or identifiable natural person.

Legal Bases for Processing

We may collect or process personal data as set forth in this Privacy Statement for the following legal bases:

• To provide you  with information and materials that you request from us.

It is in our legitimate  interests to respond to your queries and provide any information and  materials requested in order to generate and develop business. To ensure we  offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.

• To personalize our services and products and the Services to you.

It is in our legitimate  interests to market our services and products. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

For  direct marketing sent by email to new contacts (i.e. individuals who we  have not previously engaged with), we need your consent to send you unsolicited direct marketing.

• To send you  information regarding changes to our policies, other terms and conditions and other administrative information.

It is in our legitimate interests to ensure that any changes to our policies, other terms and  administrative information are communicated to you.  We consider this  use to be necessary for our legitimate interests and will not be prejudicial  or detrimental to you.

• To administer the Services including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To help keep the Services safe and secure.

For all these categories, it is in our legitimate interests to continually monitor and improve our Services and your experience of the Services and to have network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

• To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.

It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.

• To enforce the terms and conditions and any contracts entered into with you or to assert or enforce our legal rights or those of others.

We may process your personal data where necessary to perform a contract with you or to take steps to enter a contract or to comply with law or to assert or protect a legal right or obligation.

We may also process your personal data with your consent.

Your Rights and Choices

You may be able to exercise the following rights in relation to the personal data about you that we have collected (subject to certain limitations and exceptions at law):

• Right of access: you have the right to access and obtain a copy of your personal data.
• Right of portability: you have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
• Right to rectification: you have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
• Right to erasure: you have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
• Right to restriction: you have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of information in this way is not justified, such as where the accuracy of the personal data is contested by you.
• Right to object: you have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
• Right to withdraw your consent: you have the right to withdraw your consent to our processing of your personal data at any time, if such processing was based on consent.  

If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you and to fulfil our contractual obligations to you, we may not be able to perform our obligations under the contract between us. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal.  No withdrawal of consent will be effective until we receive it and have had a reasonable period of time to act on it.  You can update your details or change your privacy preferences by contacting us as provided in “Contacting Us” below.

To review, correct, update, delete, object or otherwise limit our use of your personal data that has been provided to us, or request portability and/or details of your personal data that is held by us, please contact us using the contact information listed below in the “Contacting Us” section and clearly describe your request.

If you have registered for an account with us, you can help to ensure that your personal data is accurate and up to date by logging into your account and updating your personal data.

You may unsubscribe from marketing communications at any time by clicking the “Unsubscribe” button available at the bottom of any electronic communication we may send to you. You may also unsubscribe from any medium of communication by contacting us using the information set out in the “Contacting Us” section below.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Company Group as Data Processor

In certain cases, we also operate as a data processor and we collect, process, and transfer personal data on behalf of our business customers in the provision of our services and products. In these circumstances, Vertus Group is acting as a data processor or service provider and our business customers remain the data controller in respect of personal data they provide to us.

To the extent that we are acting as data processor, we act in accordance with the instructions of such customers regarding the collection, processing, storage deletion and transfer of customer data, as well as other matters such as the provision of access to and rectification of personal data. We will only use such personal data  for the purposes of providing the services and products for which our business customers have engaged us.

Disclosure of Personal Data to Third Parties

We may share your personal data with our group companies, affiliates, subsidiaries or contractors as appropriate to carry out the purposes for which the information was supplied or collected (i.e., to provide the services and products you have requested from us) or as otherwise provided in this Privacy Statement. Personal data will also be shared with our third-party service providers and business partners who assist with the running of the Services and our business and products (including hosting providers, email service providers and payment processing partners). Our third-party service providers and business partners are subject to security and confidentiality obligations and are contractually only permitted to process your personal data for specified purposes and in accordance with our instructions.
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In addition, we may disclose personal data about you when we believe that such use or disclosure is reasonably appropriate to: comply with any legal or regulatory obligation; enforce the terms of our agreements; establish exercise or defend the rights of Company Group, our staff, customers or others protect our rights, property, safety or vital interests, or the rights property, safety or vital interests of our users or other third parties; and implement the purchase of all or substantially all of our assets, a merger, or other similar transaction that results in a change of control.

INTERNATIONAL TRANSFERS

We may transfer personal data from the EEA, UK or Switzerland to the United States and other countries, some of which have not been determined by the European Commission or relevant local data protection authority to have an adequate level of data protection. Any international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission and appropriate safeguards. While your personal information is in another jurisdiction, it may be accessed by law enforcement, the courts and other governmental authorities in that jurisdiction pursuant to the laws of that jurisdiction. If you wish to enquire further about the safeguards or our data transfer practices, please contact using the information in the “Contacting Us” section below.

SECURITY OF YOUR PERSONAL DATA

We maintain technical, physical, and administrative security controls designed to protect personal information from unauthorized use or disclosure. However, no method of transmission over the Internet, or method of electronic storage, can be 100% effective. Therefore, we cannot guarantee the absolute security of your personal information.

DATA RETENTION

The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. Your personal information may be retained for as long as appropriate to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirement, and for other legitimate purposes.  In determining how long we will retain personal information, we will consider all relevant factors.

LINKS TO THIRD PARTIES

Our Services may contain links to third party websites. These third-party websites are operated by companies that are outside of our control, and your activities at those third-party websites will be governed by the policies and practices of those third parties. Vertus Group does not in any way endorse or make any representations about such third-party websites and applications. As such, Vertus Group is not responsible for the privacy practices or content of such third-party websites and applications that are subject to their own privacy policies. If you choose to access such links, we encourage you to review all third-party site privacy policies before submitting any of your personal information.

SOCIAL MEDIA AND ONLINE ENGAGEMENT

We occasionally use a variety of new technologies and social media options to communicate and interact with customers, potential customers, employees and potential employees. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, certain of our businesses use certain third-party platforms including, but not limited to, Facebook, X, LinkedIn, Instagram, Pinterest and Google. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by us. When interacting on those websites, you may reveal certain personal data to us or to third parties. Other than when used by our employees for the purpose of responding to a specific message or request, we will not use, share, or retain your personal data.

CHILDREN’S DATA

We do not sell our products or services to children, and the Sites and Apps are not intended for or directed at children under the age of 18 years. We do not intentionally collect personal data from children under the age of 18. If you believe that we may have collected personal data from someone under the age of 18, please let us know using the methods described in this Privacy Statement.

CALIFORNIA PRIVACY DISCLOSURES

For residents of the State of California, these additional California privacy disclosures supplement the information set forth in this Privacy Statement.  

Information We Collect and How It Is Shared

In the last 12 months, we have collected each of the categories of personal information as noted in the table below and disclosed it, for business purposes, to the categories of recipients listed below. The table also indicates when we sold or shared the personal information to third parties in the last 12 months or processed such information for targeted or cross-contextual advertising and the types of third parties. For purposes of this Privacy Statement, when we use the term “third party” we mean entities that are not a Vertus Group entity or processors providing services on behalf of Vertus Group and that are not entities with whom you interact with directly.